REVIEW OF THE REPORTING REQUIREMENTS UNDER CODE SECTIONS 6055 AND 6056

Introduction
The Affordable Care Act (“ACA”) created new reporting requirements under Internal Revenue Code (“Code”) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the medical plan coverage they offer (or do not offer) to their employees.
Code Section 6055 requires insurers, insurance issuers, self-insured health plan sponsors, government agencies that administer government-sponsored health insurance programs and any other entity that provides minimum essential coverage (“MEC”) to report information on that coverage to the Internal Revenue Service (“IRS”) and covered individuals.
Code Section 6056 requires applicable large employers (“ALEs”) subject to the employer shared responsibility rules to report information on the health coverage offered to full-time employees to the IRS and covered individuals.
The additional reporting is intended to promote transparency with respect to health plan coverage and costs. It will also provide the government with information to administer other ACA mandates, such as the large employer shared responsibility penalty and the individual mandate.
On March 5, 2014, the IRS released two final regulations on the ACA’s health coverage reporting requirements.
On July 24, 2014, the IRS released draft forms relating to the information reporting requirements under Code Sections 6055 and 6056.

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